On 31 August 2025, the Uruguayan Executive Branch submitted to Parliament the National Budget Bill for the period 2025–2029. The bill proposes several tax measures, effective from 1 January 2026. The main measures are summarized below.

• Capital gains abroad: Uruguayan individual tax residents would be taxed on capital gains from foreign assets and immovable foreign assets' yields of capital. The use of intermediary entities to defer taxation is restricted.
• In-patriate regime — Tax holiday: Current beneficiaries will maintain the in-patriate regime, now extended to foreign capital gains. From 2026, new tax resident individuals would access a revised regime: full exemption on foreign capital gains for 10 years, followed by a preferential 50% tax rate for five years. Eligibility will depend on investments defined by the Executive Branch.
• Source extension — Foreign assets: Gains from transferring shares or equity in nonresident entities would be treated as Uruguayan-sourced if, within the previous 365 days, either (a) more than 50% of their assets are in Uruguay, or (b) Uruguayan assets exceed 31.5 million Indexed Units.
• Dividends: Dividends paid by local companies to foreign shareholders, which are not covered by corporate income tax (IRAE), would be subject to nonresident income tax (IRNR) withholding if the foreign jurisdiction taxes the dividends and allows a credit for Uruguayan tax withheld.
• Personal services: Compensation for personal services outside an employment relationship would now be subject to resident income tax (IRPF), and value-added tax (VAT) deductions for vehicles and other goods will be limited for IRAE taxpayers who opt into the regime.
• Talent attraction: A special regime seeks to attract qualified foreign professionals in science and technology. Eligible individuals may opt to pay IRNR, instead of IRPF, and be exempt from social security contributions under certain conditions.
• Bank secrecy: A new mechanism would allow the Tax Authority to request banking and financial information via the Central Bank of Uruguay when it has not been previously reported under Law No. 19,484. It sets deadlines, lifts bank secrecy in these cases, and imposes heavy penalties for non-compliance or improper disclosure, with fines of up to 1,000 times the maximum fine (12,680 Uruguayan pesos for 2025) under the Tax Code.
• Donations: The tax benefit for charitable donations changes to a 50/50 scheme: 50% credit and 50% deductible expense (previously 70/30 or 40/60).
• International purchases: VAT would apply to small-value online imports valued at US$20 or more, and an annual exemption would apply for total imports valued at up to US$800. Duties and taxes for a small-value imported item can be replaced by a single payment of 60% of declared value.
• Tax credit for contributing to development: The Executive Branch is authorized to grant tax credits to companies that contribute to Uruguay’s economic, technological or international development. These credits will be issued as credit certificates under the exporters’ regime, with the Executive Branch setting the conditions for their allocation.
• Domestic Top-Up Minimum Tax: A 15% minimum domestic tax is introduced for multinational groups with revenue exceeding €750m, aligned with the Organisation for Economic Co-operation and Development's (OECD's) Pillar Two. It also applies to Free Trade Zone users and is not deductible for IRAE or net wealth tax (NWT) purposes.

Parliament is currently discussing the bill, which could result in amendments to the text. The bill was submitted on August 31 and will be reviewed by both chambers, each with a 45-day deadline. If one chamber introduces amendments, the bill returns to the other chamber, which has 15 days to issue a decision. In the event of further amendments, the bill is referred to the General Assembly, which also has 15 days to issue a decision. The text of the bill is available here (available in Spanish only).